AO Cannot Issue Notice to Reopen Income Tax Assessment After 3 Years Without PR/CCIT Approval: ITAT Quashes Notice Against Saif Ali Khan

The Income Tax Appellate Tribunal (ITAT) quashed a notice issued to actor Saif Ali Khan attempting to reopen an assessment after three years without obtaining prior approval from the Principal Commissioner/Chief Commissioner of Income Tax (PR/CCIT). The ITAT noted that Section 148 of the Income Tax Act mandates such approval for reopening beyond the standard period, ensuring procedural compliance. Failure to obtain approval renders the notice invalid. The decision safeguards taxpayers against arbitrary reopening of assessments and reinforces statutory safeguards protecting long-term settled cases. It also clarifies compliance requirements for tax authorities in high-profile assessments.